MEMORANDUM No. 55-A MEMORANDUM In connection with the foregoing affidavit of Wallace H. Faulk, there is attached as an Exhibit a photostatic copy of the idle equipment report in full which is previously set out as Exhibit No. 160, supra, p. 3286. Mr. Faulk also attaches as an exhibit the correspondence between the Constructing Quartermaster and the Contractor in connection with this schedule. Mr. Faulk, however, fails to attach a follow-up letter written by the Constructing Quartermaster on August 20 in order to obtain an answer to his previous letter of August 7. (See Exhibit 213 and 214). It is noted from Mr. Faulk's exhibit that on August 21 a portion of the list was referred to the Building Department "for any comments or disposition they care to make." The following affidavits are included in the record in connection with the testimony of Philip Harrison, supra pp. 3009-3012, 3029-3034. AFFIDAVIT No. 56 [In connection with this affidavit see Affidavit No. 56-A below.] STATE OF TENNESSEE, County of Carroll: Personally appeared before me, the undersigned Notary Public in and for the said State and County, William J. Humphrey, who being duly sworn, deposes and says: My name is William J. Humphrey, and I am employed as Labor Straw Boss by the Ferguson-Oman Company on the Wolf Creek Ordnance Plant and the Milan Ordnance Depot. I have been so employed since May 1941. At the present time I live at Trenton Tennessee. Before I came to work for the Ferguson-Oman Company, I was employed by Starrett Brothers & Eken at Camp Blanding Florida. I was Superintendent of Transportation at Camp Blanding, and the issuing of trucks came under my jurisdiction on that job. In order to transport laborers from Starke, Florida to the project, we established a Convoy system and Mr. Philip W. Harrison was placed in charge of this system. His job was to use certain trucks to meet the train at Starke Florida and to haul them to the project. After the day's work was done, he was to transport the laborers back to the train. This constituted his sole responsibility at Camp Blanding. The trucks, during the day, were used on the project but were not under his control. At the peak of the employment at Camp Blanding, there were only twenty-two (22) trucks under Mr. Harrison's supervision. I understand that before Mr. Harrison was employed at Camp Blanding that he was in the insurance business in Jacksonville, Florida, for about ten (10) years. WILLIAM J. HUMPHREY. Subscribed and sworn to before me this 21 day of November, 1941. [SEAL] WINFRED H. LANCASTER, Notary Public. Registered is a Notary Public in Henderson, Carroll, and Gibson Counties, Tenn., as provided by Chap. 193, Public Acts of Tennessee 1935. My commission Expires July 10th, 1945. AFFIDAVIT No. 56-A I, Philip W. Harrison, having been sworn previously in this proceeding, make the following statement in the further support of my testimony to Mr. H. G. Robinson, knowing him to be an Investigator of the Special Senate Committee Investigating the National Defense Program. I have read the affidavit of William J. Humphreys, and to my knowledge he was never Superintendent of Transportation at Camp Blanding, Florida. He had been a private chauffeur to John McInerney, Project Superintendent, at the time they worked on the World's Fair project, and McInerney brought him to Blanding at a time when Mr. Winn was Superintendent of Transportation Equipment. Mr. Winn was assisted in his work by Mr. Robert Barnes and there was one motor pool being operated at that time and was placed under the supervision of Howard Miller, brother of Oscar E. Miller. Subsequently, a new truck lot was constructed and Mr. William Humphreys was placed in charge of that truck lot. He had mentioned to me that he would take over the supervision of both lots eventually. Whether this was accomplished or not I do not know, and at the time I left the project Miller was operating his lot and Humphreys was operating the new lot. The convoy division under my supervision worked off the lot operated by Howard Miller and was then transferred to the jurisdiction of the Personnel Department under Mr. Oscar E. Miller. Mr. Humphreys contends that at the peak of employment there were only 22 trucks under my supervision. In this connection I can state positively that the number varied from 40 to 50 trucks used for the transportation of approximately 1,000 men over 9 miles to Starke, Florida, which would have been a physical impossibility with only 22 trucks. I am attaching to my affidavit copies of letters written by Oscar E. Miller, Director of Personnel, and Russell Houldin, his successor, indicating that I was Personnel Transportation Supervisor and within a short period of time transported approximately 100,000 persons without a loss time accident. In Mr. Humphreys' letter he characterized my operation of the convoy system at Camp Blanding in one word, "excellent." (Signed) PHILIP W. HARRISON. Sworn to and subscribed to before me, at Minden, Louisiana, January 23, 1942, County of Webster. [SEAL] Mr. MARSCHardt, NANCY LEE, Notary Public (lifetime Commission). [Exhibit 1 attached to Affidavit No. 56-A] JULY 29, 1941. Room 2119, Railroad Retirement Building, Corner "C" and Third Avenues, Washington, D. C. DEAR MR. MARSCHARDT: I am writing you in behalf of Philip W. Harrison, whom I understand is submitting with this letter his noncompetitive examination, Form #375. Mr. Harrison worked under my supervision for the firm of Starrett Brothers and Eken, Inc., during the construction of Camp Blanding, Florida. He worked in the capacity of Transportation Supervisor, in which he established an excellent record. He was in charge of the motor convoys handling our personnel transportation, and transported, during a short period of time, approximately 100,000 persons without a lost time accident. Upon completion of work at Camp Blanding, I brought Mr. Harrison to the Wolf Creek Ordnance Plant at Milan, Tennessee, to handle truck and personnel transportation. In this capacity he supervised approximately 900 employees and over 800 units of equipment. He was instrumental in establishing a very fine bus system for employees to and from the plant and the surrounding communities. This operation has proved to be very profitable for the private operators. Mr. Harrison has unusual ability to quickly plan, organize, and operate units in transportation. I can highly recommend him to you as a young man with ability, initiative, and in good health, to undertake any position with you where his service might be put to good use in connection with defense work. Very truly yours FERGUSON-OMAN COMPANY OEM: bc O. E. MILLER, Director of Personnel. [Exhibit 2 attached to Affidavit No. 56-A] STARRETT BROTHERS & EKEN, INC., Mr. PHILIP HARRISON, 1269 Dancy Street, Jacksonville, Florida. DEAR MR. HARRISON: I learned with 'great regret and surprise this morning that you have accepted a job elsewhere at a higher salary. I realize, in accepting your resignation, that we are losing a man who has done an excellent job of convoying daily thousands of men in hundreds of trucks without experiencing a single mishap or accident to either the men or the trucks. I refer particularly to your being in charge of the Starrett Brothers and Eken convoying of trucks which transported men between Starke and Camp Blanding and return. This record, as you know, speaks for itself and is described by only one word, "excellent". Your conscientiousness and desire to do a good piece of work, together with your constant attention to minute details and unfailing fidelity to duty, at the same time feeling a keen responsibility for the job you had to perform leaves nothing to be desired. Please accept my congratulations and best wishes for your success in your new position. With kindest personal regards, I am RH: c RUSSELL HOULDIN, AFFIDAVIT No. 57 [In connection with this affidavit see Affidavit No. 56-A on p. 3516] STATE OF TENNESSEE, County of Carroll. Personally appeared before me, the undersigned Notary Public in said State and County, Howard Miller, who being duly sworn, deposed as follows: My name is Howard Miller. I am thirty-four years of age, and at the present time I live in Milan, Tennessee. I am employed as Assistant Superintendent of Transportation by the Ferguson-Oman Company. I am assistant to Mr. John Taylor who is General Superintendent of Transportation and Equipment. I have been employed by the Ferguson-Oman Company in various capacities since about the middle of March 1941. My first job was General Foreman of one of the truck pools maintained by the Ferguson-Oman Company. I was made Assistant Superintendent of Transportation about June 17, 1941. After I came to work for Ferguson-Oman Company, a Mr. P. W. Harrison, who was one of my superiors, installed a Convoy system consisting of approximately eighty trucks to haul laborers from the various time gates to the job locations. This Convoy system was maintained until shortly before Mr. P. W. Harrison left the employ of the Ferguson-Oman Company about the middle of June 1941, and they were under his supervision all during this time. As Wolf Creek Ordnance Plant and Milan Ordnance Depot covers an area about fifty miles square, the Ferguson-Oman Company established truck parking pools at various places on the project so that the trucks would be convenient to the various job locations. It was necessary to do this as the different job locations were scattered over such a wide area. At no time did the Ferguson-Oman Company maintain more than seven of these pools at one time which required the attention of dispatchers and clerks. Before I was employed by the Ferguson-Oman Company at the Wolf Creek Ordnance Plant and the Milan Ordnance Depot, I was employed at Camp Blanding Florida as Chief Dispatcher of the Transportation pool in the Administration Area. The general contractors at Camp Blanding were Starrett Brothers & Eken. This pool handled the dispatching and servicing of approximately three hundred fifty (350) vehicles. At the same time, there was a truck pool at the Personnel parking lot which accommodated from twelve (12) to twenty-two (22) trucks which were employed in a Convoy system and which was managed by Mr. P. W. Harrison. The number of trucks under Mr. Harrison's supervision never amounted to more than twenty-two (22). The trucks under Mr. Harrison's supervision transported the construction workers to and from Starke, Florida, which was about nine (9) miles from the Camp, and after they brought these workers to the Camp the trucks were assigned to job locations and after the days work was done, these same trucks would transport the construction workers back to the train at Starke. While the trucks were employed in the construction work, they were not under Mr. Harrison's control. It is my understanding that the operation of the Convoy system constituted the sole duties of Mr. Harrison at Camp Blanding. Mr. Harrison told me that before he was employed by Starrett Brothers & Eken at Camp Blanding Florida, that he had been an insurance agent at Jacksonville, Florida. HOWARD MILLER. Subscribed and sworn to before me this 20 day of November 1941. [SEAL] WINFRED H. LANCASTER, Notary Public. Registered as a Notary Public in Henderson, Carroll, and Gibson Counties, Tenn., as provided by Chap. 193, Public Acts of Tennessee 1935. My Commission Expires July 10th, 1945. AFFIDAVIT No. 58 [In connection with this affidavit see Affidavit No. 58-A on p. 3534; and Affidavit No. 34-A on p. 3453.] STATE OF TENNESSEE, County of Carroll. Personally appeared before me the undersigned a notary public in and for said state and county, John H. Taylor, who being duly sworn, deposed as follows: My name is John H. Taylor, I am 27 years old, my home is Greenville, Kentucky, but I have been living at Milan, Tennessee since February 1, 1941. Since that day I have been employed by Ferguson-Oman Company as Superintendent of Transportation and Equipment at Wolf Creek Ordnance Plant and Milan Ordnance Depot. I have had charge of all transportation and trucks, cars, pick up trucks and station wagons used in the construction of said plant. I also have had charge of records on rental equipment as to time and work done by rental equipment, also receiving and terminating equipment. For the past five and one-half years I have been with Oman Construction Company in various capacities. My last job with it was Project Superintendent. When I first came on the job we established one truck and car pool behind my office. At that time, where the plant was to be built was just a field and all of the employees lived in out-lying towns, Milan being the closest one, and in order to get the employees to the plant we sent trucks and cars to Milan to bring the employees in. As the work expanded and more and more employees were employed, we established other motor vehicle pools in and around the plant. After the first month, we quit going into Milan for employees and had the equipment meet them at the gates to the plant and transport them to their places of employment. The greatest number of pools ever operated at any one time by dispatchers and clerks at the plant proper was seven. At the present time there are only six such pools. We began maintaining three transportation pools outside the plant; one at Jackson, Tennessee, one at Trenton, Tennessee and one at Humboldt, Tennessee on August 8, 1941, on a directive ordered from Capt. Glen E. Hofto, CQM. (Exhibit One) I am attaching hereto a copy of the directive order delivered to me for the establishment of these three pools. They have been discontinued as of October 27, 1941 on a directive order from Capt. Glen E. Hofto, CQM. (Exhibit Two) A copy of which I am attaching hereto. When the work was originally started at the plant, Mr. Phillip W. Harrison was an employee of Ferguson-Oman Company and had charge of lining up bus transportation from the various nearby towns to the plant gates for the employees. At that time he worked under Mr. A. K. Ferguson, but shortly after the work got started, Mr. Harrison was transferred to my department as my assistant and so remained until June 17, 1941, at which time I dismissed him. The reason for his dismissal was refusal to comply with the rules and regulations of my department as established by me with the approval of Mr. W. H. Faulk, General Superintendent. Before I discharged him I took the matter up with Mr. A. K. Ferguson and Mr. W. H. Faulk, and they approved his dismissal. I understand that Mr. Harrison has testified that he recommended the discontinuance of the convoy system originally used in getting the employees from the gates to their jobs. As a matter of fact, Mr. Harrison, with my approval, instituted the original Convoy system and the same was discontinued on my orders with the approval of Mr. W. H. Faulk. About three or four days before Mr. Harrison was discharged he still insisted that it be maintained but I felt that the system which I put in prior to Mr. Harrison's leaving my department was more economic. He did not like it at all. The reason for the change from Mr. Harrison's plan was that we thought that we would save money by making the change and the new plan would be more efficient. I understand from the newspaper report from Mr. Harrison's testimony in Memphis, Tennessee, on November 18, 1941 that he claims that there were sixteen motor pools at the plant and three in outlying towns maintained by dispatchers and clerks. At no time while Mr. Harrison was my assistant or during the entire operation of the plant have there been more than seven pools at the plant and the three in out-lying towns where we maintained dispatchers and clerks. About the middle of May, 1941, in an attempt to reduce the cost of the expense of operating my part of the work, I was present at the conference between Mr. A. K. Ferguson and one of the Army Officers connected with the CQM assigned to the camp, and the suggestion was made that the "Master Re-cap of Vehicle Operation" that had been kept from the beginning of our operating could be eliminated and done away with as the Government could get the same information from other departments, and by agreement between Mr. Ferguson and the CQM, I was directed to stop making out this "Master Re-cap of Vehicle Operation". The making of same required the full services of five of my office help. After the conference I instructed Mr. Harrison that it had been agreed with the CQM that this record was no longer to be kept. He persisted in continuing to make this report out with my reduced office help, which got my office well behind with its detailed paper work and even then he was well behind in these reports. I have had no trouble after this report was done away with in keeping my work up to date with my decreased office help. |